Commitment to regulatory compliance | Binance.US 🇺🇸 Help Center

Introduction

Binance.US is a digital asset trading platform that allows clients to securely trade more than 150 different cryptocurrencies. While Binance.US is considered a non-bank financial institution, we are still required to register as a Money Services Business (“MSB”) with the Financial Crimes Enforcement Network (“FinCEN”), which we did on June 11, 2019 before launching operations on September 24, 2019. Binance.US also maintains Money Transmitter Licenses (“MTLs”) in the various states where it has registered and legally operates, and is required to comply with Anti-Money Laundering (“AML”) regulations established by the Bank Secrecy Act (“BSA”), which was amended after the 9/11 terrorist attack on the U.S. to require a Customer Identification Program (“CIP”) as part of the USA PATRIOT Act.

Compliance by Design

Since its inception, Binance.US has been committed to having an effective compliance program that meets or exceeds all applicable legal and regulatory requirements, industry standards, and business guidelines as part of the operations and management of our business. This includes having in place end-to-end BSA/AML controls, from Know Your Customer (“KYC”) and Know Your Business (“KYB”) due diligence, including Sanctions and other screenings, during the onboarding process for new customers to ongoing, real-time transaction, trade, and blockchain monitoring for existing customers. It also includes complying with local money transmitter laws in the states and territories where Binance.US holds MTLs.

Public-Private Partnerships

Today, Binance.US partners with regulators at every level of government, leading with transparency and operating in good faith with sound judgment to support the prevention of money laundering and fraud being used to support terrorism or other illicit activities. Additionally, Binance.US’s Investigations, Risk, and Compliance teams regularly partner with local law enforcement and government agencies (state and federal) to support agents with specific crypto-related criminal investigations and to provide general crypto and blockchain-related training to larger groups and departments.

Effective Compliance Program

Binance.US understands that effective compliance is achieved through a robust control framework that can be broken down into five core pillars. For our BSA/AML and Sanctions compliance program, we have the following controls in place:

BSA/AML and Sanctions Compliance Program

Pillar	Core Requirements	Binance.US Controls
Governance	Program Framework Leadership & Accountability Policies & Procedures	BSA/AML and Sanctions Program Framework BSA Officer reporting to the Chief Compliance Officer (“CCO”) BSA/AML Risk Committee composed of Senior Leaders, including the CEO, GC, CCO, COO, CFO, CISO, and Risk Board Reporting & Escalation BSA/AML and Sanctions Policy with over 60 supporting standards, procedures, and guidance documentation
Controls	Know Your Customer (KYC) Sanctions Screenings Transaction Monitoring Regulatory Reporting Information Sharing Risk Assessment	CIP Program with risk-based baseline and enhanced customer due diligence Retail KYC Standard and supporting procedures and guidance Institutional KYB Standard and supporting entity-based guidance Sanctions, PEP, and Negative News screenings and supporting procedures OFAC filing and procedures Financial Intelligence Unit (“FIU”) that performs Transaction Monitoring, Blockchain Monitoring, and assesses Trade Surveillance supported by various documented procedures Suspicious Activity Reporting (SAR) filing and procedures 314 (b) Voluntary Disclosure procedures Partnerships with local, state, and federal law enforcement (including providing crypto case investigations training to interested parties)
Training & Awareness	Training Program Communications	BSA Training Standard is in place supported by role-based training matrix BSA/AML and Sanctions Policy is provided to Binance.US employees immediately upon hiring BSA/AML and Sanctions compliance training is provided to Binance.US employees within 45 days of hiring and required at least annually thereafter (enterprise and role-based) Remedial and Ad hoc training, as well as additional communications, may also be provided to staff throughout the year
Data & Record Keeping	Data Quality Records Retention	Model validation is performed at least annually to identify the need for tuning and to ensure that our algorithms and data are valuable Records Retention Policies for both KYC records (e.g., 5 years) and transaction information
Monitoring & Testing	Compliance Monitoring Independent Audit	Annual Quality Assurance (“QA”) Assessments by function are performed, Corrective Action Plans (“CAPs”) are agreed upon, and reports are generated for tracking findings and remediation Ongoing Quality Control (“QC”) reviews for certain processes outlined at the procedure level Annual BSA/AML Compliance audit is performed by an independent, accredited third party that provides Binance.US with an executive summary of any risks and recommendations identified and a full report detailing each.